HACCP Program for Warehouse Handling Food Products- A simple Guide for Startups

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Definitions of terms used . Before we get started, let's first look at key terms to be used in this blog. Hazard Analysis Critical Control Point (HACCP) HACCP is a food safety management system that addresses food safety concerns through the analysis and control of contaminants (physical, chemical, and biological). Critical Control Points (CCP) Step in the process at which a control measure is applied to prevent or reduce a significant food safety hazard to an acceptable level. Critical limits Measurable values that separate acceptability from unacceptability. Deviation Non-fulfillment of a set requirement. Corrective actions These are actions  taken to eliminate a deviation and to prevent its recurrence. Risks Risks are the effects or consequences of the uncertainty of an event. Setting up a HACCP Program for Warehouse The food chain starts from the garden and ends at the consumer’s table. Along this chain, there are several players involved, and among these are warehouses or food

Warehouse Prerequisite Programs-Product Recall Procedure

A product recall is an action (s) taken to remove a food product from the market at any stage of the food chain, including that possessed by the final consumers. An efficient product recall process/program involves numerous components that work in close connections to each other, these include;

  • Product Recall Team
  • A complaint (trigger)
  • Traceability 
  • Mock recall
  • Product recovery and product reconciliation
  • Final disposition
  • Root cause analysis and Corrective action

Product Recall Team

For an efficient product recovery, assemble a warehouse team responsible for product recall, outlining the unique responsibilities for each individual (HACCP Team can double as a product recall team) such as one responsible for communication to the clients, media, and statutory or regulatory authority and the personnel responsible for product reconciliation and disposition of the recovered product.

 

Complaint 

A complaint is the most common trigger of a warehouse product recall. It comes in various forms, such as a customer complaint and a regulatory complaint. A customer complaint can be raised because of numerous reasons such as;

  • Contaminated product
  • Health effects after consuming the product
  • Expired product 
  • Wrong or misleading product labeling
  • Sabotaged or adulterated product

Once a complaint has been raised by a customer, the warehouse customer care personnel records down various details of the product that will be vital for tracing and identifying the consignment in question. These details include the following;

  • Product name
  • Product batch number
  • Expiry date
  • Date of purchase
  • Customer location
  • pictorial evidence (if required).

 

Traceability

As the name suggests, traceability has an element of tracing, in this case, tracing for a food product through all the handling processes of the warehouse. 

Since this blog handles food products and other related products like food packaging materials, we define traceability as the ability to follow the history, application, movement, and location of an object through specified stages of production, processing, and distribution.

There are two approaches to traceability; one-step-back to the supplier of food products and one-step-forward (to the consumer) approach.

As the most vital part of a product recall, traceability plays a role in;

  • Identifying product details like date of receipt, amount, and batch number of the product in question or under investigation received at the warehouse. Product details are in receiving records and Good Received Notes (GRNs).
  • Identifying the amount of the consignment under investigation that is still at the warehouse or that which was dispatched to clients using documents such as Dispatch Monitoring Form and Inventory Monitoring Form.

Mock recall

To test whether the established product recall of the warehouse is working and efficient, the product recall team at specific periods conducts a mock product recall. 

Just like how fire drills prepare workers for actual fire incidents, the mock recall does the same for the recall team of the warehouse in case of a product recall.

It's advisable to conduct a mock recall annually and document every outcome, noting the failures and opportunities. These (failures and opportunities) contribute enormously to the continuous improvement of the warehouse's product recall system or procedure. A mock recall comprises but not limited to the following;

  • The date and time the activity was initiated, preferably after working hours when there are no other activities taking place at the warehouse.
  • An overview of the records and documents reviewed to obtain the actual amount of a product recalled.
  • A documented review by the product recall team that shows the mock product recall effectiveness including issues and opportunities for improvement, amounts of the food or a related product recovered, and outcome of the exercise.

In case the mock recovery exercise fails (less than 100% product recovered), it's advisable to repeat the exercise, correcting the flaws within 60 days. However, the warehouse management can choose a much less time frame depending on its operations.

 

Product recovery and reconciliation 

The product recall procedure is based mainly on documentation and the recording principle of the HACCP Program. Without proper documentation of the HACCP program, there are minimal to zero chances of a successful recovery and reconciliation of food or a related product that was received, stored, or dispatched from the warehouse. For a product recall to be successful, all the affected food product is recovered and withdrawn from the food chain.

Note: 

The main objective of a product recall is to prevent the consumption of food products that can pose health risks to the consumers. It is done by locating deviant food products and promptly removing them from the food chain and accurately communicating to the affected customers as soon as possible about the product defect; the hazard associated with the product, and the corrective action.

Final disposition

A product recall plan of the warehouse must show the handling of the recovered products, and a procedure followed to track and control all the defective products returned to the warehouse. The final disposition includes actions such as; returning the product to the supplier or destroying all the deviant products.

 

Root cause analysis and corrective action

Root cause analysis ensures that a condition or a set of conditions that led to the product recall is identified and understood in-depth, gathering all the necessary information about the product. After conducting a Root cause analysis comes corrective actions that eliminate the cause of a non-conformity to prevent a recurrence.

Corrective actions include by are not limited to;

  • Training staff
  • Change of process
  • Change of documents 

 

Procedure 

Assemble a product recall team for your facility/warehouse. In case there is a HACCP team already in place, it can serve as a product recall team with a few added individuals with well-defined duties or responsibilities. Just like the HACCP Team, a product recall team must also have a leader responsible for coordinating all activities of other team members. A product recall team includes but not limited to the following;

  • Warehouse decision-makers
  • Marketing/ sale department
  • Quality assurance department
  • Customer care department
  • Legal counsel

 

Develop a communication plan to reach out to all stakeholders involved and should contain internal and external contact. The internal phone contacts are those of the warehouse recall team that must always be available 24/7. At minimal, the communication plan includes the following;

  • When to Communicate to the media (If necessary or required by the law) and the person responsible.
  • When to communicate to the authority or regulatory organs? If required by the local laws.
  • When to notify the public or customers about the recall?

Identify the records and documents used to trace the affected product at the warehouse, on the delivery truck, or delivered to the final client. The identified records must contain all the necessary product details that are vital in uniquely identifying the product in question and these include but are not limited to;

Develop plans for withdrawing the affected product (in case it's already dispatched from the warehouse) and separating the affected products from the rest of the products in case the product is still in the warehouse. These include non-conforming the affected product and recording the product details in the non-conforming record.

Note:

A product recall can be voluntarily initiated by the warehouse management(voluntary product recall) or compulsory by the local authority after a questionable discovery regarding a particular product. 

You can do a product recall for a warehouse following a decision tree below



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